September 19, 2011
The Hon. Frank G. Jackson
Cleveland City Hall
601 Lakeside Ave.
Cleveland, OH 44113
Dear Mayor Jackson,
We are writing in regard to the “municipal waste to energy” facility that Cleveland Public Power
is proposing to build at the Ridge Road transfer station. The city has submitted a draft permit
application to Ohio EPA for this gasification facility, which is classified as an incinerator under
federal regulations.
As public interest advocates, we want to help Cleveland residents to understand the health,
environmental, and financial consequences of the proposed facility. This will help Clevelanders
weigh in with informed opinions as they communicate with Council and the Mayor on this
important public policy question. Our organizations have submitted numerous public requests to
the various city departments involved with this project, and have found that much of the key
information that would help us to determine the impacts of this facility has been withheld from
the public. We have outlined below several key questions we have about this proposal..
1)
What are the dangers from air pollution from this facility for residents and businesses
in the neighborhood and the region?
Neighborhoods, churches, 19 schools, a recreation center, a Cleveland Metropark, the Zoo, 3
food processing companies and 21community gardens are close to the Ridge Road site.
Gasification involves the cooking of trash at high temperatures and the release of toxic pollutants
into the air. In fact, according to presentations we have received from CPP, the facility would
become one of the top air polluters in Cuyahoga County.
The air permit application which we have received through our public records requests is highly
redacted and fails to answer many key questions. Has either the Cleveland Law Department or
Ohio EPA issued a legal opinion that allows key information on emissions to be withheld from
either the agencies or the public? If so,, we would like to have a copy of this opinion.
So far, we have been able to determine the following:
 The facility would be by far the biggest mercury polluter in the county. In fact, this one
facility would put more than 10 times more mercury into the air than all other facilities
combined. Lake Erie fish contaminated by this mercury, when eaten by pregnant women,
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can poison their developing fetus with a potent neurotoxin.
The facility would be one of the top polluters of soot (known as particulate matter), in the
county. Data from the city indicate this facility would emit more particulate air pollution
than the CEI Lakeshore Plant, Cleveland Thermal or the Medical Center Co. Exposure
can aggravate asthma, and has been linked to heart and lung disease.
The facility has been promoted by CPP as “clean energy.” What is the definition of
“clean” in this case? Since it will only produce 20 megawatts of electricity, but emit
significant amounts of pollution, it appears to be more polluting per megawatt of
electricity produced than other forms of “dirty” energy.
The air permit is extremely vague on what would be burned at this facility. Peter Tien,
the developer, has told the media that the facility could burn “…scrap paper, wood
pallets, chemicals, medical waste, pharmaceutical waste, chemical liquids, flammable
liquids, tires, rubber, plastics - anything you can think of." (WCPN “Sound of Ideas,”
3/1/10). This raises the question as to whether the permit application accurately reflects
what types of waste will actually be burned. Depending on what is incinerated, there is a
high potential for release of very hazardous pollution into the community, including
dioxins.
Because the city wants to bring trash from other municipalities into the Ridge Rd. facility,
there will be increased truck traffic with its accompanying pollution, and the traffic is
likely to create a “diesel hot spot.”
The air pollution could cause damage to any nearby businesses that process or grow food.
Another proposed facility in Mahoning County, which CPP has said would have similar
emissions to this facility, was cancelled earlier this year due to opposition from a nearby
manufacturer of food packaging, who contended that emissions from the facility would
contaminate his products.
2) What will the project cost, and what will those costs mean for city residents, especially
customers of Cleveland Public Power?
The City has released figures saying the facility will cost $180 million, including the cost of
building a facility to collect trash and sort recyclables. However, the City has said these costs
are not yet firm and that financing has not been worked out. Last year, Cleveland added a new
trash fee for residents – and if costs for this project goes up, the City has not said what effect it
would have on trash fees.
Cost projections are difficult because there are currently no commercial-scale solid waste
gasification systems operating in the U.S. After decades of study by large cities and state
governments from California to Florida, no functioning gasification plants have been built to
handle municipal trash in the country beyond a handful of small demonstration facilities. A
similar proposed facility by the same developer, in Clyde, Ohio, was cancelled because it was
too expensive. This proposed project is an unproven combination of technologies that does not
exist anywhere in the world.
Because Cleveland Public Power would be committed to purchasing electricity from the new
plant, it would be stuck with the costs no matter what they are – and CPP is already losing its
competitive edge with FirstEnergy. Cleveland Public Power already owes AMP up to $8 million
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for the failed coal plant proposal in Meigs County. AMP is also involved in the potential
financing of the Ridge Road plant. Is it prudent for the city to undertake another development
project with AMP that could end up having to increase electric rates to pay the money back?
3) Why does Cleveland Public Power continue to rely on Peter Tien despite a history of
broken promises?
The city’s partner in developing the proposal is Princeton Environmental Group, led by Peter
Tien – the same individual who was the key player in the city’s failed Sunpo Optu LED light
bulb project.
The terms of the contract between CPP and Princeton Environmental Group, signed on March
30, 2010, stated: “Consultant (Princeton Environmental Group) shall establish an office in
Cleveland, Ohio, and staff it with residents of the Greater Cleveland area on or before March 31,
2010.” Although Princeton Environmental Group still has no local phone book listing for an
office, we were able to find an address on an invoice that Princeton Environmental Group sent to
CPP in June 2010. The invoice, which has a New Jersey phone number, listed a local office at
1120 Chester. However, our visit to the local office this summer has shown that it is simply an
empty room with a sign on the wall, housed in the offices of the Ralph Tyler Companies. Has
the Princeton Environmental Group defaulted on its eighteen-month old contractual obligation to
hire local residents?
Princeton Environmental Group was also required to provide numerous documents to CPP on a
timeline that was outlined in the contract. We have received very little information on this in our
public records requests, but it appears that many of these deadlines were not met.
4)
Is there a better way for Cleveland to handle its trash and protect the environment?
Your “Sustainable Cleveland 2019 Project” has committed to a goal of Zero Waste. Zero Waste
means establishing a goal and a plan to invest in the infrastructure, workforce, and local
strategies needed to eliminate our dependence on both landfills and incinerators.
But would relying on gasification become a disincentive to establishing environmentally-friendly
recycling, pollution prevention, green energy and green technologies in Cleveland? Neil
Seldman, from the Institute for Local Self-Reliance, estimates that for every 10,000 tons of waste
incinerated one job will be created. For every 10,000 tons of waste recycled and composted 4-10
local jobs will be created and then go on to provide more jobs in those sectors. We could be
sacrificing the opportunity to create hundreds of jobs in the city and build small businesses.
Recycling is more energy efficient than combustion. Recycling and composting far exceed all
other waste management options in reducing greenhouse gas emissions. Creating the gasification
facility could become a disincentive for waste minimization and recycling, since the electricgeneration part of the plant will always need to be “fed” to produce electricity.
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We would like to meet with you to discuss these important issues and the information gaps we
have noted. We appreciate your deep love of and concern for Cleveland's neighborhoods, but
we are troubled that those who live and work closest to this facility will be most impacted by
harmful emissions, and that pollutants will be carried long distances and persist in our
environment for decades. We will continue to work with you to encourage the use of safer nonincineration technologies, recycling, materials recovery, pollution prevention, composting, and
other downstream waste practices. Thank you for consideration of this letter. .
Sincerely,
Stuart Greenberg, Executive Director
Environmental Health Watch
3500 Lorain Ave, Suite 302
Cleveland, OH 44113
216-961-4646
Chris Trepal, Executive Director
Earth Day Coalition
3606 Bridge Ave.
Cleveland, OH 44113
216-281-6468
Sandy Buchanan, Executive Director
Ohio Citizen Action
614 W. Superior Ave, Suite 1200
Cleveland, OH 44113
216-861-5200
cc: Martin Sweeney, President, Cleveland City Council
Kevin Kelley, Public Utilities Committee Chair , Cleveland City Council
Matt Zone, Sustainability Subcommittee Chair , Cleveland City Council
Andrew Watterson, Chief of Sustainability, Office of the Mayor
Ivan Henderson, Commissioner, Cleveland Public Power
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